PRIVACY POLICY

Last updated date: September 20, 2022

Concierto.Cloud is committed to respecting your privacy while using our website. This Concierto.Cloud Data Privacy Notice defines the requirements to ensure compliance with the applicable data privacy laws and regulations applicable to Concierto.Cloud collection, use, and transmission of Personal Data and Sensitive Personal Data for information collected by us.

Concierto.Cloud respects the privacy of data subjects and is committed to complying with the applicable data privacy laws and legislations (including but not limited to EU General Data Protection Regulation 2016/679, California Consumer Privacy Act, The Privacy Act 1988 (Australia) including the Australian Privacy Principles (APP), Data Protection Act 2018 (UK), Information Technology Act 2000 and other applicable privacy laws to the extent that they apply to Concierto.Cloud data processing and business operations)

2. Privacy Notice

Concierto.Cloud Data Privacy Notice is designed to explain and set out Concierto.Cloud procedures and policies when processing Personal Data and Sensitive Personal Data by the organization. This Notice defines the requirements to ensure compliance with the Data Privacy Laws applicable to Concierto.Cloud collection, use, and transmission of Personal Data and Sensitive Personal Data.

Concierto.Cloud is committed to protecting your personal and sensitive data by:

  • Acting in a Lawful, fair and transparent manner;
  • Using the data collected for the intended purpose only;
  • Storing your Personal Data no longer than is necessary;
  • Protecting confidentiality, integrity and accuracy of the data captured;
  • Safeguarding anonymity of the Personal Data by using appropriate technical and organizational measures;
  • Ensuring Data Privacy rights of the Data Subjects are in accordance with legitimate business rights and Data Privacy Regulations; and
  • Holding ourselves accountable and compliant with Data Privacy Regulations.

Protecting your Personal Data is an important concern for us. In this Privacy Notice, we explain how we collect your data, what we do with it, for what purposes we use it, how we keep it safe, and how you can exercise your data rights.

Key Definitions “Personal Data” or “Personal Information” used synonymously, means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of Concierto.Cloud (or its representatives or service providers).

Concierto.Cloud, hereafter known as "us," "we," or "our," operates the Concierto.Cloud website (the “Website”).“You”, “Your”, refers to the individual visiting this website and sharing Personal Data for Business or Employment purposes.

Questions and Concerns

If you have any questions or concerns about Concierto.Cloud handling of your Personal Data, or about this Notice, please contact us using the following contact information:

Our Contact Information

Concierto.Cloud
2350 Mission College Blvd., Suite 1250, Santa Clara, CA 95054
E-Mail: [email protected]

We are usually able to resolve Privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from our Privacy Team, you may escalate concerns to the applicable Privacy regulator in your jurisdiction. Upon request, Concierto.Cloud Privacy Team will provide you with the contact information for that regulator.

What Data do we collect from you?

We may collect different types of Personal Data to understand your preferences, customize services, and improve your user experience. We may process the data as per the Concierto.Cloud purposes as described below in Data Usage section, in alignment with this Privacy Notice and in compliance with applicable Data Privacy Laws legislations (including but not limited to EU General Data Protection Regulation 2016/679, California Consumer Privacy Act, The Privacy Act 1988 (Australia) including the Australian Privacy Principles (APP), Data Protection Act 2018 (UK), Information Technology Act 2000 and other applicable privacy laws to the extent that they apply to Concierto.Cloud data processing and business operations)

When you visit our website as a user either as a Prospective Client or Prospective Employee etc. but not limited to, we will collect and process the following Personal Data and other information about you from one or more of the following places as applicable:

  • Directly from you;
  • From other sources like Networking sites, Job portals etc; and
  • When we generate it ourselves.

Such information may include (by way of non-exhaustive list):

  • Email address;
  • First name and last name;
  • Phone number;
  • Address, state, province, city, zip/ postal code;
  • Cookies data 
  • Usage data on how the Website is being browsed and used, including diagnostic data such as your browser application, browser version, pages visited, your computer’s Internet Protocol (IP) address, date and time of visit, time spent on individual pages, and device accessed from; and
  • Data that you submit when filling out forms on our Website, including information that you may provide when inquiring about our services, downloading collaterals, signing up for events, providing feedback, or when participating in our opinion surveys.
  • Data that you submit when filling out forms on our Website, including information that you may provide for your career at Concierto.Cloud

What purpose do we use your data for?

We use your Personal Data for various purposes which includes:

  • To understand your needs and interests;
  • For the management and administration of our business;
  • Customizing topics of interest based on your site visit preferences;
  • Detecting, preventing and addressing technical issues to conduct analysis required to detect malicious data and understand how this may affect your IT system;
  • To allow you to use and access the functionality provided by the Website;
  • To communicate with you in in response to queries submitted via online forms on the Website;
  • To send marketing alerts on our offers and services
  • To comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures, including the Terms of Use;
  • Monitoring the Website performance and fine-tuning our offerings; and
  • Analyzing information to improve the Website.
  • Allow prospective employees to apply for jobs

When do we transfer your data?

The Purpose Description for data collection, transfer, storage, usage, processing, reporting, retention, and removal is governed by Concierto.Cloud Privacy Notice and bound by legitimate business requirements and applicable Data Privacy Laws. (including but not limited to EU General Data Protection Regulation 2016/679, California Consumer Privacy Act, The Privacy Act 1988 (Australia) including the Australian Privacy Principles (APP), Data Protection Act 2018 (UK), Information Technology Act 2000 and other applicable privacy laws to the extent that they apply to Concierto.Cloud data processing and business operations)

Whom do we share your data with?

We may share your Personal Data within the Concierto.Cloud group of companies for the purposes described above. In addition, we may disclose your Personal Data in the circumstances outlined below:

  • In order to comply with a legal and regulatory obligations;
  • Investigate any possible misconduct in connection with the Website;
  • Defend and protect the rights and properties of Concierto.Cloud;
  • As part of a transaction, financing, or for other business needs;
  • With third-party service providers and other professional service organizations to analyze the Website’s usage, performance, and other Website-related activities on our behalf in order to keep our Website current and or to aggregate, analyze, derive business insights and identify potential business opportunities from the data. These service providers will be subject to confidentiality requirements (either by contract, professional obligation or otherwise) and they will only use your Personal Data as described in this Privacy Notice.

How we ensure security to your Data?

Security of your personal and sensitive data is important to us. We are compliant to ISO27001:2013(Information Security Management System), ISO 27701:2019(Privacy Information Management System), American Institute of Certified Public Accountants (AICPA) Trust Principles. We leverage on these standards and control frameworks enabled by the technology to provide a secure environment for maintaining the confidentiality, integrity and availability (CIA) and Privacy of our internal systems’, clients’ and Website visitors’ data. As a condition of employment, Concierto.Cloud employees are required to follow all applicable Laws and Regulations, including in relation to Data Protection Laws. Access to Personal Data is limited to those employees who need it to perform their roles. Unauthorised use or disclosure of confidential client information by a Concierto.Cloud employee is prohibited and may result in disciplinary measures.

How long do we keep your data?

For how long Concierto.Cloud will hold your Personal Data will vary and will be determined by the following criteria:

  • Concierto.Cloud is required to retain the Personal Data for as long as is necessary to satisfy or meet the purpose for which it was obtained or any other legal purpose. Legal obligations: Laws or Regulations may set a minimum period for which Concierto.Cloud must retain your Personal Data.
  • Retention schedules are arrived based on the above mentioned criteria and hence disposal of data will follow defined retention schedules.

Children's Privacy

Our Website is not intended for anyone under the age of 16 or below. If you get to know that your Children has provided their Personal Data to us, please contact us at [email protected]. We will take necessary steps to remove the information.

We have links to other Sites

We may include links to other websites, third-party sites, and services on our Website which are not operated by us. We advise you to review the Privacy Statement of every external website that you visit as we will not have control over their content, policies or practices. If you choose to click on the external links hosted on our Website, your Data Privacy will be governed by the respective external website’s Privacy statements/Policies. Concierto.Cloud does not take any responsibility for any data breach experienced if you choose to provide any Personal Data on the externally-hosted website.

Changes to this Privacy Statement

We may add, change or update this Privacy Statement from time to time. Please review this page periodically. All the changes will become effective from the time they are posted on the Website. The modification date will be posted at the top of this webpage, besides the heading “Last updated date.”

If you have any questions related to this Privacy Statement, or to report any Data Privacy concerns, please email us at [email protected].

Section applicable to you if you are an European Union (EU) resident

Where EU Data Protection Laws apply, the provisions in this section will apply in addition to the general provisions set out above.

Pursuant to EU Data Protection Laws, Concierto.Cloud is the Controller of your Personal Data collected and processed via the Website.

Where we transfer your Personal Data to another country outside the European Economic Area, we will ensure that it is protected and transferred in a manner consistent with legal and regulatory requirements. In relation to data being transferred outside of Europe, for example, this may be done in one of the following ways:

  • The country that we send the data to might be approved by the European Commission as offering an adequate level of Protection for Personal Data;
  • The recipient might have signed up to a contract based on “Standard  contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
  • In other circumstances the Law may permit us to otherwise transfer your Personal Data outside Europe.

You can obtain more details of the Protection given to your Personal Data when it is transferred outside Europe (including a copy of the standard Data Protection clauses which we have entered into with recipients of your Personal Data) by contacting us using the contact details given in this site.

In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:

  • The right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
  • The right to withdraw your given consent wherever applicable to the processing of your Personal Data at any time. Please note, however, that this might affect the Processing operations related to your Data
  • In some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and or or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Concierto.Cloud;
  • The right to request that we rectify your Personal Data if it is inaccurate or incomplete;
  • The right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
  • The right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but there might be legal grounds to refuse that request; and
  • The right to lodge a complaint with the relevant Data Protection regulator if you think that any of your rights have been infringed by us.
  • Since there is no automated decision making process, this right to object to automated decision making process is inapplicable

You can exercise your rights by contacting us at contact details provided in “Our Contact Information” Section

Section applicable to you if you are a California resident

If you are a California resident and sharing your Personal Data for Business Purposes, you are covered by the CCPA (California Consumer Privacy Act) You may have certain rights under the CCPA as listed below. We will comply with your request in accordance with, and to the extent permissible under, applicable Law. This section is in addition to standard PrivacyNotice sections mentioned in the beginning of this Policy.

Rights under the CCPA and How to Exercise Them

Access

  • You have the right to request that we disclose to you the following information about the last 12 months:
  • The categories and specific pieces of Personal Information we have collected about you
  • The categories of sources from which your Personal Information was collected
  • The business or commercial purpose for collecting or selling your Personal Information (we do not sell your Personal Information) and
  • The categories of third parties with whom we have shared your Personal Information.

Deletion

You have the right to request that we and our service providers delete any Personal Information which we have collected from you. We and our service providers will not delete your Personal Information if it is necessary or permissible for us or our service providers to maintain the Personal Information pursuant to the CCPA or other applicable Law.

Information about Our Sharing Of Personal Information

You have the right to request that we disclose to you the following information about the last 12 months:

  • Whether we have sold your Personal Information (please note that we do not sell your Personal Information); and
  • The categories of Personal Information we have disclosed about you for a business purpose and the categories of third parties to whom the Personal Information was disclosed.

You can exercise your rights listed above, or reach out to us with questions or concerns about our Privacy statements and practices in the contact details mentioned in this Privacy Notice. Note that, pursuant to the CCPA, you will not receive discriminatory treatment from us if you choose to exercise any of your CCPA rights.

When you submit a CCPA request, you may be needed to provide certain verification information when requested, such as your name, phone number, postal address, email address etc. This information will be used to help us detect potential fraud, verify your identity, and fulfil and respond to your request. We will not store or use this information for any other purpose.

You can exercise your rights by contacting us at contact details provided in “Our Contact Information” Section

Section applicable to you if you are an Australian citizen or permanent resident

Our Australian business is bound by the Privacy Act 1998 (Australia) and we shall protect your personal information according to that Act and other applicable laws

Rights under Australian privacy act and how to exercise them

Privacy statement copy

You have the right to request for our Privacy Statement in a particular form. We shall take reasonable steps in providing the same to you.

Access

  • You have the right to request that we disclose to you the following Personal Data
  • The categories and specific pieces of Personal Data we have collected about you
  • The primary and secondary purposes for which Personal Data has been used or disclosed
  • The sources from which your Personal Data was collected and
  • The categories of overseas recipient or third party with whom we have shared your Personal Data

Correction

We are obliged to take reasonable steps to correct your Personal Data to ensure that the data is accurate, up-to-date, complete, relevant and not misleading. You also have the right for requesting correction of Personal Data.

Overseas data transfer

We may share Personal Data to overseas recipient who is

  • Not in Australia or external territory
  • Not an APP(Australian Privacy Principle) entity
  • Not the individual to whom the Personal Data relates
  • To countries of our Business operations, but not limited to India and US

after taking reasonable steps to ensure that the overseas recipient does not breach Personal Data. We will ensure that overseas recipient handles Personal Data in accordance with Australian Privacy Principles. These precautions are taken to ensure free flow of Personal Data across borders with the privacy of the individuals respected.

You can exercise your rights by contacting us at contact details provided in “Our Contact Information” Section

Lodging a complaint

If you have any concerns about how we have handled your personal information, you may contact us at contact details provided in “Our Contact Information” Section

All complaints should initially be in writing and directed to the contact details as mentioned above. We will investigate your issue, notify you of our response and will keep records of our investigation and resolution. If you are not satisfied with the manner in which we have dealt with your complaint, you may contact the Office of the Australian Information Commissioner whose contact details are available at www.oaic.gov.au

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